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United States Government Accountability Office:
GAO:
Testimony:
Before the Subcommittee on Early Childhood, Elementary, and Secondary
Education, Committee on Education and the Workforce, House of
Representatives:
For Release on Delivery:
Expected at 10:00 a.m. EDT:
Thursday, June 27, 2013:
School Lunch:
Modifications Needed to Some of the New Nutrition Standards:
Statement of Kay E. Brown, Director:
Education, Workforce, and Income Security:
GAO-13-708T:
GAO Highlights:
Highlights of GAO-13-708T, a report to Subcommittee on Early
Childhood, Elementary, and Secondary Education, Committee on Education
and the Workforce, House of Representatives.
Why GAO Did This Study:
The National School Lunch Program served 31.6 million children in
fiscal year 2012, in part through $11.6 billion in federal supports.
The most recent reauthorization of the program, the Healthy, Hunger-
Free Kids Act of 2010 required that nutrition standards for school
lunches be updated. As a result, USDA issued final regulations aimed
at providing lunches high in nutrients and low in calories that better
meet the dietary needs of school children and required that many be
implemented in school year 2012-2013. The new rules provide detailed
requirements for meal components—fruits, vegetables, grains, meats,
and milk; update requirements for calories, sodium, and fats; and
require that each student’s lunch contain a fruit or vegetable.
To provide information on challenges that school districts have faced,
this testimony draws on work GAO conducted as part of its ongoing
study of implementation of the changes. Specifically, GAO reviewed
relevant federal laws, as well as USDA regulations, guidance, and
studies; interviewed USDA officials and groups of food service
officials and relevant industry representatives; and visited eight
school districts. The districts varied by geographic location, size,
and certain student and food services characteristics.
What GAO Found:
School districts across the country faced several challenges
implementing the new lunch requirements in school year 2012-2013, and
the U.S. Department of Agriculture’s (USDA) response to some of these
challenges has been limited. For example, because USDA regulations
restrict the amounts of meats and grains that can be served in school
lunches each week, all eight districts GAO visited needed to modify or
eliminate popular menu items. These changes sometimes led to negative
student reactions, including a 3-week student-led boycott of school
lunch in one district. The meat and grain restrictions also led to
smaller lunch entrees, making it difficult for some schools to meet
minimum calorie requirements for lunches without adding items, such as
gelatin, that generally do not improve the nutritional quality of
lunches. In response to feedback from states and districts regarding
operational challenges caused by the meat and grain restrictions, USDA
lifted the limits temporarily, first for the remainder of school year
2012-2013 and then for school year 2013-2014. USDA officials said they
did not see a problem making the temporary changes to help with
implementation because the limits on meats and grains and the limits
on the calories in lunches are somewhat redundant, as both address
portion size. However, because the change was seen as temporary, the
eight districts GAO visited made only marginal changes to their menus.
Rather, several district food services officials, as well as relevant
industry representatives, indicated the need for a permanent federal
decision on these restrictions, which USDA has also acknowledged.
The calorie range requirements for lunches also challenged some
districts, particularly those with schools that include students from
both grades 6-8 and 9-12. Because the required lunch calorie ranges
for these two grade groups do not overlap, districts with such schools
face difficulties planning menus and serving lunches that comply with
both requirements. For example, one food services official, whose
district includes schools serving 7th through 12th graders, developed
menus with calorie counts between the grades 6-8 maximum and the
grades 9-12 minimum, leaving the lunches out of compliance with both
sets of restrictions. Although USDA has acknowledged that menu
planning in such schools can be challenging, USDA’s current guidance
does not provide these districts flexibility to assist their efforts
to comply. Rather, guidance suggests that students from different
grades be provided with different lunches, a solution that may be
impractical in schools in which students of different grades share
lunch periods and serving lines.
Although the eight districts GAO visited expressed support for the
improvements to the nutritional quality of school lunch, they reported
additional challenges meeting the new requirements, such as student
acceptance, food waste, costs, and participation. For example, USDA
requires that meals include whole grain-rich products and certain
vegetables, but most districts noted that obtaining student acceptance
of foods like whole grain pasta and beans has been challenging. If
students do not accept these items, the result may be increased food
waste or decreased participation in the lunch program, which were
concerns in most districts GAO visited. However, student acceptance of
the changes will likely improve over time, as indicated by their
positive comments about healthy food and consumption of fruits and
vegetables in most districts GAO visited.
What GAO Recommends:
GAO recommends that USDA permanently remove the meat and grain maximum
requirements and allow flexibility to help districts comply with the
lack of overlap in the calorie ranges for grades 6-8 and 9-12 lunches.
View [hyperlink, http://www.gao.gov/products/GAO-13-708T]. For more
information, contact Kay E. Brown at (202) 512-7215 or brownke@gao.gov.
[End of section]
Chairman Rokita and Members of the Subcommittee,
I am pleased to participate in today's discussion of school districts'
experiences implementing the new requirements for the National School
Lunch Program. This program served 31.6 million children in fiscal
year 2012, supported in part through federal subsidies and commodities
totaling $11.6 billion. Although federal requirements for the content
of school lunches have existed since the program's creation, the
Healthy, Hunger-Free Kids Act of 2010--the law that most recently
reauthorized school meal programs--required that they be updated by
the U.S. Department of Agriculture (USDA), which administers the
National School Lunch Program. In response, USDA updated requirements
for the content of lunches based on the recommendations of the
Institute of Medicine.[Footnote 1] USDA issued final regulations
defining these new requirements in January 2012, and required the
implementation of many of these requirements beginning in school year
2012-2013. USDA's updated regulations aim to provide lunches high in
nutrients and low in calories that better meet the dietary needs of
school children and protect their health. To that end, the regulations
make several changes and additions to the previous requirements for
the content of school lunches, such as the new requirement that each
student's lunch contain at least one fruit or vegetable. Under
agreements with state agencies, local school food authorities (SFAs),
which are generally aligned with school districts, serve meals to
children in schools and are the entities responsible for implementing
these requirements.
As school year 2012-2013 has progressed, both USDA and the media have
reported that states, SFAs, school officials, parents, and students
have expressed some concerns about the school lunch changes. While the
changes to school lunch are the primary school food changes required
to be implemented in school year 2012-2013, the Healthy, Hunger-Free
Kids Act of 2010 also required similar updates to nutrition standards
for the School Breakfast Program and other foods sold in schools--or
competitive foods--which will be implemented in future school years.
As a result, issues that have arisen because of implementation of the
school lunch changes may have implications for future changes.
My remarks today will generally address challenges that school
districts faced implementing the new school lunch requirements in
school year 2012-2013. This information was gathered using several
methods, including reviews of relevant federal laws, regulations, and
guidance; interviews of USDA officials, a group of eight SFA directors
representing both their own districts and their regions of the
country, and a group of eleven relevant industry representatives;
[Footnote 2] and site visits conducted to eight school districts
across the country. This work was conducted as part of our current
study of implementation of the school lunch changes, in which we are
assessing the extent to which school lunch participation changed
during school year 2012-2013, implementation challenges, and USDA's
assistance with implementation of the new requirements.[Footnote 3]
Our site visits were conducted between March and May 2013, and my
remarks represent some of our findings from these visits. The school
districts selected for these visits provide variation across
geographic location, district size, and certain characteristics of the
student population and district food services.[Footnote 4] For
example, we visited districts that generally prepare school lunches in
one central kitchen before delivering them to schools, districts that
prepare lunches in kitchens on-site in each school, and others that
use alternative approaches for lunch preparation. Seven of the school
districts we visited manage their own food service operations, while
one district contracts with food service management companies. In each
district, we met with SFA staff at the district and school levels,
school administrators, and students, and we observed lunch in at least
two schools of different grade levels. We also interviewed the eight
state child nutrition program directors overseeing these districts.
Although both public and non-profit private elementary and secondary
schools, as well as residential child care institutions, participate
in the National School Lunch Program, all of the districts we visited
were public. We cannot generalize our findings from the site visits
beyond the school districts we visited.
My remarks also reflect our reviews of relevant USDA data and studies.
For example, we reviewed USDA's School Nutrition Dietary Assessment
Study IV (2012), which provides information on school lunches and
other foods sold in schools nationwide in school year 2009-
2010.[Footnote 5] Further, because it is the basis for USDA's revised
regulations on the content of school lunches, we reviewed the
Institute of Medicine's report, School Meals: Building Blocks for
Healthy Children (2010).[Footnote 6] We assessed the methodologies and
findings of the studies we reviewed and determined that they were
sufficiently reliable for the purposes of this testimony.
We conducted this work as part of our ongoing performance audit on
implementation of the new school lunch requirements from February 2013
through June 2013 in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit
objectives. We believe that the evidence obtained provides a
reasonable basis for our findings and conclusions based on our audit
objectives.
Background:
The National School Lunch Program, established in 1946, is intended to
safeguard the health and well-being of the nation's children. The
program provides nutritionally balanced low-cost or free lunches in
participating schools to about 31 million children each month. At the
federal level, USDA's Food and Nutrition Service oversees the program,
which is administered by states and local SFAs. In fiscal year 2012,
the federal government spent over $11 billion on the National School
Lunch Program. Specifically, USDA provides reimbursement in the form
of cash subsidies and donated commodities based on the number of
lunches served that meet certain federal requirements. Although
federal requirements for the content of school lunches have existed
since the program's inception, as research has documented changes in
the diets of Americans and the increasing incidence of overweight and
obesity in the U.S., federal lunch requirements have become
increasingly focused on improving the nutritional content of lunches.
The Healthy, Hunger-Free Kids Act of 2010, which most recently
reauthorized the National School Lunch Program, required changes to
the federal lunch requirements with the intention of reducing
childhood obesity and improving children's diets. Since 1994, federal
law has required SFAs to serve school lunches that are consistent with
the Dietary Guidelines for Americans,[Footnote 7] and in 2004, federal
law required USDA to issue federal rules providing SFAs with specific
recommendations for lunches consistent with the most recently
published version of the Guidelines. As a result of that requirement,
USDA asked the Institute of Medicine to review the food and
nutritional needs of school-aged children in the United States using
the 2005 Dietary Guidelines for Americans and provide recommended
revisions to meal requirements for the National School Lunch Program.
The Institute published its final report in 2010, and also in that
year, the Healthy, Hunger-Free Kids Act of 2010 required USDA to
update the lunch requirements based on these recommendations. The
Institute's report recommended changes to the lunch component and
nutrition requirements in place at the time. Regarding the lunch
components--fruits, vegetables, grains, meats, and milk--the Institute
recommended offering both fruits and vegetables daily, increasing
whole grain-rich foods, offering only fat-free and low-fat milk, and
limiting the amount of grains and meats/meat alternates served each
week. Regarding the nutrition requirements, the Institute recommended
including both minimum and maximum calorie levels for lunches,
increasing the emphasis on limiting saturated fat and minimizing trans
fat, and reducing sodium content. USDA issued a proposed rule on the
new lunch requirements in January 2011[Footnote 8] and a final rule in
January 2012.[Footnote 9] The final rule required implementation of
many of the new lunch requirements beginning in school year 2012-2013.
Since the final rule was issued, USDA has provided extensive guidance,
as well as technical assistanceand training, to states and SFAs to
assist with implementation of the new requirements
The Eight SFAs We Visited Faced Several Challenges Implementing the
New Lunch Requirements:
All Were Challenged by Meat and Grain Limits:
Because regulations issued in January 2012 by USDA placed limits on
the amounts of meats/meat alternates and grains that can be included
in a school lunch, all eight SFAs we visited modified or eliminated
some popular menu items, leading to negative student reactions in some
districts. USDA's new regulations specify the minimum and maximum
weekly number of ounces of meats, cheese, or other meat alternates and
the minimum and maximum weekly number of ounces of grains to be served
with lunch, which differ by grade level.[Footnote 10] In comparison,
the previous regulations only specified the minimum number of ounces
of meats and grains required to be served with lunch each week. (See
table 1.) Officials in one of the districts we visited told us that,
in response to the new limits, cheeseburgers were removed from the
elementary and middle school lunch menus because adding cheese to the
district's burger patties would have made it difficult to stay within
the weekly meat maximums. In another district, the SFA reported that
it switched from using shredded cheese on the chili dog to processed
cheese sauce because it does not count as a meat alternate. A similar
type of switch occurred in one of the districts we visited because of
the grain maximums. That SFA reported that it changed from serving a
whole grain chip to a potato chip because the potato chip did not
count as a grain. The grain maximums also affected popular lunch
items, such as sandwiches. For example, four districts we visited
reduced certain grain options used for sandwiches, such as the sub
roll and the tortilla wrap, and two districts stopped serving peanut
butter and jelly sandwiches as a daily option in elementary schools
because the weekly grain maximum did not allow for a sandwich to be
served every day. SFAs in four of the districts we visited noted that
student reactions to these menu item changes were generally negative,
and some said the changes had impacts on participation, that is, the
number of students purchasing school lunches. For example, the
tortilla wrap size change in one district was followed by a
significant decrease in the number of students selecting their lunches
from the previously popular deli sandwich line in the high schools, as
well as a decrease in the overall percentage of students purchasing
school lunches in those schools. Another district's change to its sub
roll contributed to a middle and high school student boycott of school
lunch that lasted for 3 weeks.
Table 1: The Previous Federal Requirements for Weekly Meat and Grain
Portions in School Lunches Compared to School Year 2012-2013
Requirements:
Previous Federal Requirements - Minimums:
Grade Level: K-3;
Meat (in ounces): 7.5;
Grain (in ounces): 8 or 10[B];
Grade Level: 4-12;
Meat (in ounces): 10;
Grain (in ounces): 8 or 12[B];
Grade Level: 7-12[A];
Meat (in ounces): 10 or 15[B];
Grain (in ounces): 8 or 15[B];
School Year 2012-2013 Requirements - Minimums and Maximums:
Grade Level: K-5;
Meat (in ounces): 8-10;
Grain (in ounces): 8-9;
Grade Level: 6-8;
Meat (in ounces): 9-10;
Grain (in ounces): 8-10;
Grade Level: 9-12;
Meat (in ounces): 10-12;
Grain (in ounces): 10-12.
Source: USDA Analysis of Previous and Current Requirements, 77 Fed.
Reg. 4088, 4113.
[A] This was an optional grade configuration allowed under the
previous federal requirements.
[B] Under the previous federal requirements for school lunch, SFAs
could choose to use one of five approved approaches to plan their
menus. Three of these approaches focused on nutrient requirements and
did not specify portion size requirements. The two approaches that
included portion sizes requirements differed in the minimum
requirements for certain grade levels, as shown in the table.
[End of table]
To comply with both the meat and grain maximums and the required
calorie minimums for lunches, some districts added foods that
generally did not improve the nutritional value of lunches. In the new
requirements, USDA specified daily minimum and maximum calorie levels
for school lunches by grade group (K-5, 6-8, and 9-12), which lunch
menus must meet on average over the school week. However, because the
entrée, typically consisting of meat and grain, generally provides the
majority of the calories in the meal, the weekly meat and grain
maximums that limit the size of entrées in effect also limited the
calories of the lunches. As a result, five SFAs we visited reported
that the meat and grain maximums made it difficult to plan menus that
met the minimum calorie requirement for grade 9-12 lunches--750
calories. To comply, some SFAs added foods to the menus that, while
allowable, generally do not improve the nutritional value of lunches.
For example, in three of the districts we visited, the SFAs reported
adding pudding to certain high school menus to bring the menus into
compliance with the calorie minimum. Some SFAs also added gelatin, ice
cream, or condiments such as butter, jelly, ranch dressing, or cheese
sauce to become compliant, according to the districts we visited and
the SFA and industry groups we spoke with. While these additional menu
items provided needed calories to lunches, they also likely increased
the amount of sugar, sodium, or fat in the meal, potentially
undercutting the federal law's goal of improving the nutritional
quality of lunches.[Footnote 11]
Some SFAs noted that obtaining meat and grain products from food
vendors that complied with the new requirements was a continual and
evolving process during school year 2012-2013 because vendors were
continually modifying products throughout the year. For example, four
SFAs we visited said they met regularly with vendors during school
year 2012-2013 as vendors worked to bring their products into
compliance. One of those SFAs reported working closely with food
manufacturers and vendors throughout the summer of 2012 to find
appropriate products, including a 1.5 ounce burger patty--which is
less than half the size of a ¼ pound burger--that allowed the district
to continue to serve cheeseburgers to all students. Representatives
from a group of food manufacturers and other relevant industries we
spoke with indicated that the meat and grain maximums were challenging
to respond to in part because the grain maximums had unexpectedly
changed between the proposed and final rules, and the time between
issuance of the final regulations and required implementation was
short.[Footnote 12] Some noted that while they were eventually able to
reformulate their products to comply with the new requirements, the
process took longer than the 6 months available between issuance of
the final rule and the required implementation date.[Footnote 13]
In response to feedback from states and SFAs regarding operational
challenges caused by the meat and grain maximums, USDA lifted the
maximums temporarily. First, in December 2012, USDA issued guidance
allowing states to consider SFAs to be in compliance with the
requirements for school year 2012-2013 if their menus exceeded the
weekly meat and grain maximums. A few months later, in February 2013,
USDA provided the same flexibility for school year 2013-2014,
acknowledging that SFAs needed guidance to help with meal planning and
food procurement for the coming school year, as SFAs often plan menus
and order or contract for food beginning in the winter of the previous
school year. The February guidance also stated that USDA understands
the need for longer term guidance on this issue and is considering
options for addressing the meat and grain maximums beyond school year
2013-2014. In May 2013, USDA officials told us that the Department
wanted to be responsive to the challenges they had heard about, and
they did not see a problem making the temporary change to help with
implementation because the meat and grain maximums and the calorie
maximums both accomplish the goal of addressing portion size, making
them somewhat redundant.[Footnote 14] Although this implies that USDA
may permanently remove the meat and grain maximums, USDA officials
told us that the Department is still considering options for a long-
term solution to the meat and grain maximums and has not yet made a
permanent decision.
None of the eight SFAs we visited made substantial changes to their
menus in response to USDA's temporary removal of the weekly meat and
grain maximums. Reasons that SFAs cited for this decision included:
the flexibility was temporary, districts had already modified their
menus to comply with the new requirements, products were already
ordered for those menus, staff were already trained, and students had
been educated about the new requirements. Instead, those SFAs that
made some modifications after the flexibility was allowed focused on
marginal changes that would ease menu planning and improve student
acceptance of lunches. For example, in the district in which students
reacted strongly to the decreased size of the tortilla wrap for
sandwiches, the SFA brought in a larger wrap, though it was still
smaller than the wrap used previously. Further, in the district that
experienced a student boycott of lunch in part because of the change
to the sub roll, the sub roll used in prior school years returned to
the high school lunch menus. In another district that had decreased
the amount of mini corn dogs they provided to each elementary school
student because of the maximums, additional mini corn dogs were added
to each student's portion.
SFA directors, food manufacturers, and other relevant industry
representatives indicated the need for a timely and permanent federal
decision on these maximums. Specifically, some SFA directors we
visited told us that it is difficult to know how to proceed with menu
planning under the new requirements when the flexibility provided over
the maximums continues to be temporary. The School Nutrition
Association, which represents SFAs across the country, has indicated
that it supports the permanent elimination of the meat and grain
maximums, because their removal will give cafeterias more flexibility
to design healthy menus that meet nutrition standards and student
tastes. Although the flexibility exists for school year 2013-2014,
because USDA has given SFAs mixed messages regarding the Department's
future plans for the meat and grain maximums, SFAs are currently left
guessing about the future outcome, making planning future budgets and
food ordering difficult. Several industry representatives said that
because some SFAs are planning menus that comply with the maximums,
while others are planning menus that include larger meat and grain
portion sizes, industry is experiencing difficulties forecasting
demand, which leads to food production, inventory, and storage
challenges. This situation will soon become more complicated because
of the impending federal changes to the content of meals served
through the School Breakfast Program and other foods sold in schools.
Calorie Requirements for Middle and High Schools Also Challenged Some
SFAs:
Because the required calorie ranges for grades 6-8 and 9-12 do not
overlap, schools with students in both these grade groups faced
challenges complying with the calorie requirements. While the grades K-
5 and 6-8 average daily calorie ranges for school lunches overlap at
550-650 and 600-700, the grades 6-8 and 9-12 ranges, which are 600-700
and 750-850, do not.[Footnote 15] This creates a challenge for schools
that include students from both grade groups, including schools in two
of the districts we visited. One SFA director, whose district includes
schools serving 7th through 12th graders, noted that complying with
both of the calorie range requirements is particularly difficult when
students in different grades use the same serving lines and share a
lunch period. The director noted that cashiers at the point-of-sale
may not know each student's grade level, which complicates the
accurate identification of a meal that complies with the requirements.
In addition, if certain food items are offered to some students and
not to others depending on their grade, students may react negatively
to the differential treatment. Because of these implementation issues,
this district planned its menus to generally provide 725 calorie
lunches for all students in these schools, which are not in compliance
with either of the required ranges, and could potentially result in
fiscal action against the SFA in the future.[Footnote 16]
USDA's response to this issue, provided in part through the
Department's guidance on menu planning under the new lunch
requirements, has been limited. In the proposed rule on the new lunch
requirements, USDA indicated that the new requirements are expected to
bring about positive outcomes, including simplification of school
lunch administration and operations. However, in comments on the
proposed rule, some school districts expressed concerns that the lack
of overlap in the calorie ranges may lead to increased costs and
administrative burden. Although USDA did not change the ranges in the
final rule, in its guidance on the new requirements, the Department
acknowledges that the lack of overlap in the calorie ranges for these
grade groups can be challenging. Because of this, USDA's guidance
suggests that districts serve a menu appropriate for the lower grade
level and add a few additional foods for students in the upper grade
level. This differs from the previous requirements, which allowed
schools to comply with meal requirements for the predominant grade
group in schools that included students from two different groups.
USDA's guidance also differs to some extent from the approach
recommended by the Institute of Medicine in its report on which the
federal requirements are based. The report's authors suggested that,
for schools serving students from multiple grade groups on the same
serving line, the SFA should work with the state agency to find a
solution that ensures the basic elements of the standards for menu
planning will be maintained, including moderate calorie values.
Student Acceptance Has Been a Challenge to Some Extent:
While all eight SFAs we visited expressed support for the goal of
improving the nutritional quality of lunches and felt the new
requirements were moving in that direction, all eight experienced
various challenges related to student acceptance of some of the foods
served to comply with the requirements. Under the new requirements,
lunches must include whole grain-rich products and vegetables from 5
sub-groups each week,[Footnote 17] and districts we visited noted that
obtaining student acceptance of some whole grain-rich products and
vegetables in the beans and peas (legumes) and red-orange sub-groups
have been challenging. For example, six districts mentioned student
acceptance of whole grain breads or pasta as being a challenge.
Regarding vegetable sub-groups, five districts we visited said that
they have had difficulty obtaining student acceptance of the beans and
peas (legumes) sub-group, and two districts expressed difficulty with
sweet potatoes, in the red-orange sub-group. Some noted that they have
continued to try new recipes throughout the year to address these
challenges, but acceptance has been limited. Challenges with student
acceptance of these foods were foreseen by the Institute of Medicine
in its report recommending they be required components of school
lunch, as national data showed that few students reported eating these
types of foods. The researchers noted that implementation of effective
educational, marketing, and food preparation strategies, as well as
the increased availability of suitable and appetizing products, may
improve student acceptance of these foods.
Some districts reported that, if the past is an indicator, student
acceptance of these foods may improve over time, and student comments
regarding other healthy foods they like suggest this as well. In four
of the districts we visited, SFA directors noted that they had begun
adding whole grains into their menus before the current school year,
and they have seen student acceptance of whole grain products improve
over time. In addition, one district's SFA director also noted that
acceptance of foods in the beans and peas (legumes) sub-group has
improved over time. When we talked to students in the schools we
visited and asked them about lunch foods they do not like, these
specific foods were mentioned by some students in four of the eight
districts, but most students focused their comments on other
vegetables or specific entrees. Further, most of the students we
talked to indicated that they like to eat healthy and nutritious
foods, and they think that school lunches generally provide such
foods. Although school year 2012-2013 is the first year that students
were required to take a fruit or a vegetable with school lunch
nationwide, when we asked students what they like about school lunch
this year, students in 13 of the 17 schools we visited to observe
lunch reported liking certain fruit and vegetable options.
Food waste is also an indicator of lack of student acceptance of the
new lunch requirements. Students may take the food components they are
required to as part of the school lunch, but they may then choose not
to consume them. Although none of the districts we visited had fully
analyzed food waste over the past few years to determine if it changed
during school year 2012-2013,[Footnote 18] six of the SFAs we visited
told us they believe food waste has increased because of the new lunch
requirements. In particular, SFAs said that the fruits and vegetables
students are now required to take sometimes end up thrown away, and in
our lunch period observations in 7 of 17 schools, we saw many students
throw some or all of their fruits and vegetables away. However, at the
same time, we observed other students take and consume sizable
quantities of fruits and vegetables and the other lunch components in
the remaining 10 schools in which we observed lunch, resulting in
minimal food waste. Four of the SFAs we visited talked about food
waste being more of an issue with the youngest elementary school
students, possibly because of the amount of food served with the lunch
and the amount of time they have to consume it. The Institute of
Medicine report acknowledged differences in food intake among
elementary students, noting that the amounts of food offered under the
new recommendations may be too large for some of the younger
elementary school children because they are more likely to have lower
energy needs than the older children in the same grade group. In
USDA's final rule, the Department discussed the offer versus serve
policy, which has been required for senior high schools and optional
for all other schools since 1975, as a way to minimize food waste.
Under the current regulations, this policy allows students to decline
two of the five meal components offered with the lunch, rather than
requiring students to be served all five components.[Footnote 19]
However, the SFA director in one of the districts we visited noted
that the district has chosen not to implement the offer versus serve
policy for the youngest students because they have difficulty making
choices, which extends the time spent in the serving line and
decreases the time students have to consume their lunch.
Student participation in lunch has decreased to some extent in school
year 2012-2013, which is another indicator that student acceptance of
school lunches may have declined since the changes. Most of the SFAs
we visited reported that they experienced decreases in lunch
participation in school year 2012-2013 in part because of the new
lunch requirements and other factors.[Footnote 20] USDA's national
data, which do not account for adjustments related to changes in
monthly serving days or student enrollment across years, also
generally show that student lunch participation was lower in school
year 2012-2013 than it was the year before. Later this year, when we
complete our study of the school lunch changes, we plan to provide
additional information on lunch participation trends.
SFAs Faced Other Challenges, Including Hunger Concerns and Increased
Costs:
SFAs also faced concerns in school year 2012-2013 that the new lunch
requirements were leaving some students hungry--an issue raised in
five of the districts we visited. For example, in one district, a high
school principal told us that during school year 2012-2013, athletic
coaches expressed concerns that student athletes were hungrier after
school than they were in previous years, and staff reported that more
students were distracted during the final period of the school day
than in previous years. In the district we visited in which middle and
high school students boycotted school lunch at the beginning of the
year, the boycott was led by two student athletes in part because they
indicated that the lunches were leaving them hungry. These concerns
were likely related to decreased entrée sizes. During our visits to
schools, students in six schools mentioned that they have been hungry
this year after eating school lunch because of various reasons. For
example, students in three schools attributed this to the smaller
entrees, and students in one of those schools also noted that it may
be related to the timing of their lunch periods, as their school's
first lunch period began around 10: 30 a.m. and the school day ended
at about 2: 30 p.m. In another school, students acknowledged that they
had not taken or eaten all of the items offered with the lunch, which
we observed resulted in a smaller sized lunch. (See figure 1.) In
contrast, when students served themselves all of the lunch components
in the districts that we visited, their lunches were substantially
larger in size, primarily because of the large amounts of fruits and
vegetables they selected. (See figure 2.)
Figure 1: Three Food Component Lunches:
[Refer to PDF for image: 2 photographs]
Source: GAO.
Note: Food components included in the lunches shown are: grain, fruit,
and milk in the lunch on the left; and grain, fruit, and meat
alternate (yogurt) in the lunch on the right.
[End of figure]
Figure 2: Five Food Component Lunches:
[Refer to PDF for image: 2 photographs]
Source: GAO.
Note: Food components included in both the lunches shown are grain,
meat/meat alternate, fruit, vegetable, and milk.
[End of figure]
School lunches generally provide fewer calories under the new
requirements than in past years, likely because of smaller entrée
sizes. Specifically, the new required lunch calorie maximums for each
grade group are either lower or comparable to the calorie minimums
previously required. As a result, school lunches generally provided
more calories in the past, according to national data, than they are
allowed to in school year 2012-2013, particularly for younger
students.[Footnote 21] Although the previous nutrition standards were
developed to align school lunches with the Dietary Guidelines for
Americans, they were developed in the mid 1990s. Since then, the
percentage of children who are overweight and obese has increased, and
research has shown that excess food consumption, poor food choices,
and decreased physical activity contribute to these trends. The
Institute of Medicine's 2010 recommendations for the lunch pattern
were developed using a data-based approach, which assessed data on
healthy weights and heights, physical activity, and the distribution
of calories among meals, and the authors indicate that the recommended
lunches are appropriate for the level of physical activity of most
children.
SFAs also expressed concerns about the impact of compliance with the
new lunch requirements on food costs and their budgets. All eight SFAs
we visited reported that they have incurred increases in fruit and
vegetable costs this year because of the requirement that students
take at least one fruit or vegetable with lunch. Further, most
indicated that overall costs for school lunch were greater in school
year 2012-2013 than in the past, and three expressed concerns about
the impact of these changes on their overall financial stability.
Because we conducted our visits before the end of the school year, we
have not yet obtained data from these SFAs on how they ended the year
financially, though we plan to provide information on those results in
our final report.
All eight SFAs we visited also discussed other challenges implementing
the lunch changes during school year 2012-2013, such as additional
menu planning issues, food procurement, new requirements related to
the price of lunches, the pace of implementation, and USDA's
assistance with the changes. When we complete our study of the lunch
changes later this year, we will provide additional information about
implementation challenges and USDA's assistance to states and SFAs
with implementation.
SFAs Noted Concerns about the Proposed Competitive Foods Changes:
In addition to the school lunch changes, the Healthy Hunger-Free Kids
Act of 2010 required that USDA specify and require nutrition standards
for all foods and beverages sold outside the school meals programs on
the school campus during the school day, which are commonly referred
to as competitive foods because they compete with school meal
programs. Competitive foods are often sold through vending machines,
school stores, and fundraisers, and also include SFA sales of a la
carte items in the cafeteria. In school year 2009-2010, competitive
foods were sold in an estimated 93 percent of schools nationwide,
according to a recent USDA study.[Footnote 22] The proposed rule
containing these standards was published by USDA in February
2013,[Footnote 23] and during our visits to SFAs, many expressed
concerns that certain aspects of the proposed rule would be
challenging to implement, if finalized.[Footnote 24]
Specifically, seven of the eight SFAs we visited expressed concerns
about what they viewed as a lack of clarity in the proposed rule
regarding how the nutrition standards for competitive food sales
administered by entities other than the SFA will be enforced. In our
2005 report on competitive foods,[Footnote 25] we found that many
different people made decisions about competitive food sales, but no
one person commonly had responsibility for all sales in a school. At
that time, in a majority of schools nationwide, district officials
made competitive food policies, while SFA directors and principals
made decisions about specific sales. Other groups, such as student
clubs and booster groups, also made competitive food decisions through
their direct involvement in sales. The number and variety of groups
involved in these sales typically increased as the school level
increased. For example, an estimated 48 percent of middle schools
nationwide had three or more groups involved in these sales compared
to an estimated 83 percent of high schools. Although a 2004 law
required districts to implement wellness policies in school year 2006-
2007 that addressed nutritional guidelines for all foods available in
schools during the school day, some of the SFAs we recently visited
told us that these policies have generally not been enforced, in part
because no one person was granted enforcement responsibility over all
such sales.[Footnote 26]
SFAs we visited also expressed concern that the proposed rule's
inclusion of differing nutrition standards based on the type of
competitive foods sale will put the SFA at a competitive disadvantage
relative to other food sales within a school. For example, five SFA
directors expressed concerns about the proposed rule's provision
allowing states discretion to make decisions about fundraisers that
are exempt from the federal nutrition standards for competitive foods.
Some SFA directors expressed concerns that this would potentially
result in inconsistent treatment, whereby SFAs' competitive food sales
would be required to follow the nutrition standards and fundraisers
would not. Similarly, some SFAs expressed concerns about the proposed
rule's inclusion of different standards for beverages sold in food
service areas during meal periods--which are typically sold through
SFA a la carte sales--and beverages sold outside of meal service
areas--such as those through vending machines. Specifically, although
the proposed rule allows the sale of milk, water, and juice through
any competitive food venue at any time, the rule also allows the sale
of other beverages, except for in food service areas during meal
periods. However, this restriction is somewhat similar to the current
federal requirements on competitive food sales.[Footnote 27]
Conclusions:
Across the country, more nutritious school lunches likely were
provided to students during school year 2012-2013. All eight SFAs we
visited expressed support for the goal of improving the nutritional
quality of lunches and felt the new federal requirements were moving
in that direction. Many students' positive comments on healthy foods,
their views that school lunches generally provide such foods, and
their consumption of sizable quantities of fruits and vegetables in
the majority of schools we visited indicate that acceptance of the new
lunch requirements will improve over time. However, as the first year
of implementation of the new requirements for the content of school
lunches has unfolded, the SFAs we visited also faced a variety of
challenges.
While some of the challenges SFAs faced this year have been addressed
and others may become less difficult as time elapses, those caused by
the required weekly maximum amounts of meats and grains permitted in
lunches and the lack of overlap in the allowable calorie ranges for
grades 6-8 and 9-12 likely will not. Because of the meat and grain
maximums, some districts made menu decisions that are inconsistent
with the goal of improving children's diets, as they added desserts
and condiments that increased the amount of sugar, salt, or fat in
lunches in order to comply with the required calorie minimums.
Acknowledging that the meat and grain maximums created challenges for
SFAs, USDA lifted them through school year 2013-2014 and indicated
that the maximums may not be needed to accomplish the nutrition goals
of the new requirements. However, although USDA has acknowledged the
need for a permanent decision on the maximums, they have yet to
provide one, hindering the ability of school districts to plan menus,
food purchases, budgets, staff training, and student education because
they do not know whether the meat and grain restrictions will be
reinstated in the future or not. In addition, the requirements that
lunches served to students in grades 6-8 provide different amounts of
calories than lunches served to students in grades 9-12--even in
schools that serve students in both grade groups--is inconsistent with
past practices, expert recommendations, and USDA's intent of
simplifying the administration and operations of the school lunch
program. Most significantly, the inflexibility of these calorie
requirements substantially hinders certain SFAs' ability to comply,
which may potentially result in fiscal action against SFAs in future
years. Absent a permanent USDA decision to remove the meat and grain
maximums and increase flexibility for schools that serve meals to
students in both the 6-8 and 9-12 grade groupings, SFAs will continue
to face challenges implementing the regulations, potentially impeding
their efforts to meet their key goals--healthier foods in school for
healthier students.
Recommendations:
To improve SFAs' ability to design menus that comply with the new
lunch requirements, we recommend that the Secretary of Agriculture:
* permanently remove the weekly meat/meat alternate and grain maximums
for school lunch defined in federal regulations, and:
* modify federal regulations or guidance to allow school districts
flexibility in complying with the defined calorie ranges for schools
with students in both the grades 6-8 and 9-12 groups.
We provided a draft of this testimony to USDA for review and comment.
In oral comments, USDA officials indicated that they generallya greed
with our recommendation regarding meats and grains, and they are
currently developing an approach for permanently lifting the meat
and grain maximums. Officials added that while they recognize the need
to address the challenges posed by lack of overlap in the calorie ranges
for grades 6-8 and 9-12, it is important to identify a solution to this
issue that ensures calorie ranges remain appropriately targeted to students
based on their ages—-a point emphasized by the Institute of Medicine. USDA
officials also said that they have been collecting information on
implementation of the new lunch requirements throughout the year from many
school districts and have heard about implementation challenges. However,
according to USDA officials, official reporting by states indicates that a
majority of districts have been able to comply with the new requirements.
USDA also expressed concern that the findings in the testimony did not reflect
a nationally representative sample of school districts. We continue to believe
that our site visits to eight school districts and our interviews with eight
SFA directors from across the country, state officials, and industry
representatives enabled us to identify some of the challenges school districts
are facing in implementing the new nutrition standards. Our final report will
provide additional information and data to inform these issues.
Chairman Rokita and Members of the Subcommittee, this concludes my statement.
I would be pleased to respond to questions you may have.
Contacts and Staff Acknowledgments:
For further questions on this testimony, please contact me at (202)
512-7215 or brownke@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this statement. Individuals who made key contributions to this
statement include Jessica Botsford, Robert Campbell, Rachel Frisk,
Kathy Larin, Jean McSween, Dan Meyer, and Zachary Sivo.
[End of section]
Footnotes:
[1] Pub. L. No. 111-296 § 201, 124 Stat. 3183, 3214. As required by
the law, USDA updated the nutrition standards based on recommendations
issued by the Food and Nutrition Board of the National Research
Council of the National Academies of Science, part of the Institute of
Medicine. Throughout this report, we refer to these as the Institute
of Medicine's recommendations.
[2] The School Nutrition Association (SNA), a national non-profit
organization representing 55,000 members involved in serving meals to
children in schools, assisted our efforts to speak with these groups.
The eight SFA directors we spoke with were representatives on SNA's
public policy and legislation committee, which includes representatives
from each region of the country, as well as SNA's board of directors.
None of these SFA directors were responsible for administering the
National School Lunch Program in districts that we selected for site
visits, and only one of the SFA directors was from a state in which
we conducted a site visit. The 11 industry representatives we spoke
with were members of SNA, and some serve on the Association's industry
advisory board.
[3] We anticipate issuing a final report on this study in late 2013.
[4] We conducted site visits to Caddo Parish Public Schools (LA),
Carlisle Area School District (PA), Chicago Public Schools (IL), Coeur
d'Alene School District (ID), Fairfax County Public Schools (VA),
Irving Independent School District (TX), Mukwonago Area School
District (WI), and Spokane Public Schools (WA).
[5] U.S. Department of Agriculture, Food and Nutrition Service, Office
of Research and Analysis, School Nutrition Dietary Assessment Study IV
(Alexandria, VA: November 2012).
[6] Institute of Medicine, School Meals: Building Blocks for Healthy
Children (Washington, D.C.: The National Academies Press, 2010).
[7] The Dietary Guidelines for Americans were first issued in 1980,
and most recently issued in 2010. The Secretaries of Agriculture and
Health and Human Services are required, at least every 5 years, to
publish a report entitled "Dietary Guidelines for Americans" based on
current scientific and medical knowledge.
[8] Nutrition Standards in the National School Lunch and School
Breakfast Programs, 76 Fed. Reg. 2494 (proposed Jan.13, 2011) (to be
codified at 7 C.F.R. pts. 210 and 220).
[9] Nutrition Standards in the National School Lunch and School
Breakfast Programs, 77 Fed. Reg. 4088 (Jan. 26, 2012) (codified at 7
C.F.R. pts. 210 and 220).
[10] The new regulations also specify the minimum number of ounces of
meats and grains that must be served each day but do not specify the
maximum number of ounces of meats and grains that must be served each
day.
[11] However, lunches in which these menu items are added must still
comply with the new nutrition requirements, which currently include
limits on the amount of fat in school lunches. Beginning in school
year 2014-2015, the new nutrition requirements also limit the amount
of sodium in lunches.
[12] The weekly grain maximums for grades K-5 and 9-12 were higher in
the proposed rule than in the final rule, as they changed from 10 to 9
ounces and 13 to 12 ounces, respectively. USDA officials explained
that they made the change because they could not implement the
proposed rule's limit on starchy vegetables due to a provision in the
Consolidated and Further Continuing Appropriations Act of 2012, Pub.
L. No. 112-55, which prevented USDA from implementing any maximum
limits on vegetables. USDA officials said that they lowered the
maximum weekly ounces of grains to limit the overall starchy items
served with lunch. Concerning timing, the final rule was issued
January 26, 2012 with implementation required by July 1, 2012, which
was the beginning of school year 2012-2013.
[13] Some industry representatives noted that because of the need to
focus on product reformulation throughout the school year, they have
been unable to direct efforts to new product development to provide
districts with additional food options that comply with the new
requirements.
[14] The Institute of Medicine report on which USDA based the new
lunch requirements states that both the food component and calorie
requirements are needed to achieve alignment with the Dietary
Guidelines for Americans, which is why they recommended including both
the calorie ranges and the weekly amounts for each food component,
including meats and grains. However, although the Institute attempted
to analyze the recommendations with respect to likely benefits and
negative consequences, its report noted that the evidence on which to
base such predictions is limited. As a result, the Institute may not
have foreseen the operational challenges associated with the meat and
grain maximums.
[15] The Institute of Medicine report used data-based methods to
provide a basis for the calculation of appropriate values for mean
total daily calorie requirements for students in the three grade
groups. Specifically, the report indicates that calorie range
recommendations are based on reference growth chart data for healthy
weights and heights, objective data on physical activity, and data on
how calories are distributed among meals and snacks consumed by
schoolchildren.
[16] Under USDA regulations, an SFA found to have served meals not in
compliance with requirements is potentially subject to fiscal action,
such as the recovery of federal reimbursements for those meals.
[17] Regarding the grains component of the lunch, federal regulations
require that all grain products must be made with enriched and whole
grain meal or flour, and whole grain-rich products must contain at
least 51 percent whole grains. Beginning July 1, 2012, half of the
grain products offered during the school week must meet the whole
grain-rich criteria, and beginning July 1, 2014, all grain products
must meet these criteria. Regarding the vegetables component of the
lunch, federal regulations define the minimum weekly serving sizes for
each of the vegetable sub-groups--dark green vegetables, red-orange
vegetables, beans and peas (legumes), starchy vegetables, and other
vegetables.
[18] One of the districts we visited has been working with a
university researcher on a plate waste study, but a final report has
yet to be issued.
[19] However, under the current regulations, students must select at
least ½ cup of the fruit or vegetable component with their lunches.
[20] While we obtained some lunch participation data from the
districts we visited, we have not yet fully analyzed the changes they
experienced.
[21] National data from school year 2009-2010 show that the average
calorie content of school lunch offered was 726 in elementary schools,
785 in middle schools, and 843 in high schools; see School Nutrition
Dietary Assessment Study IV, 2012. The average daily maximum calorie
content for lunches under the new federal requirements is: 650 for
grades K-5, 700 for grades 6-8 and 850 for grades 9-12.
[22] School Nutrition Dietary Assessment Study IV (2012).
[23] National School Lunch Program and School Breakfast Program:
Nutrition Standards for All Foods Sold In School as Required by the
Healthy, Hunger-Free Kids Act of 2010, 78 Fed. Reg. 9530 (proposed
Feb. 8, 2013) (to be codified at 7 C.F.R. pts. 210 and 220).
[24] USDA sought public comments on the proposed rule and will
consider these comments in finalizing the rule. For purposes of this
testimony, we did not review or analyze the comments submitted in
response to the proposed rulemaking. To view the comments that were
submitted in response to the proposed rule, visit [hyperlink,
http://www.regulations.gov]. The comments described in this testimony
were shared with us by SFAs during our site visits and may or may not
echo themes that were raised by those officially commenting on the
proposed rule.
[25] GAO, School Meal Programs: Competitive Foods are Widely Available
and Generate Substantial Revenues for Schools, [hyperlink,
http://www.gao.gov/products/GAO-05-563] (Washington, D.C.: Aug. 8,
2005).
[26] Recognizing this, as part of a broader city campaign on health
and wellness, one of the districts we visited recently created a
separate department responsible for health and wellness initiatives,
including enforcement of the district's wellness policy and
nutritional guidelines for all foods sold in schools.
[27] Currently, federal regulations prohibit the sale of certain
competitive foods, known as foods of minimal nutritional value (FMNV),
during meal periods in school cafeterias and other food service areas.
FMNV, as defined by USDA, include soda, chewing gum, and hard candy,
for example.
[End of section]
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